I’ve heard a lot of Sam Stans say that Sam strangling Dean during their fight in When The Leeve Breaks was “justified” because Sam was angry at Dean for locking him up in the Panic Room and calling him a monster. That Sam had done it purely out of passion. Apart from the fact that being angry is never an excuse to strangle someone, the passion argument is complete bullshit.
The fight was already over and Sam had clearly won it. Dean was lying on the floor across the room in a pile of broken glass and wood. He wasn’t going to get up and go after Sam again. Sam could have walked out of that room and gone after Ruby. Instead, Sam stood there for a second and then proceeded to walk over to Dean, climb on top of him and strangle him.
Sam strangled Dean intentionally. Sam wanted to strangle Dean.